◆Announcement of Revisions to Supervision and Guidance Regarding Overtime Work, etc.

On August 19, Reiwa 8, the Ministry of Health, Labor and Welfare announced that, based on the contents of the “Japan Growth Strategy” and the “Basic Policy on Economic and Fiscal Management and Reform 2026,” starting September 1 of this year, Work Style Reform Promotion Support Centers and Labor Standards Inspection Offices nationwide will undertake the following initiatives: (1) enhancing consultation and support regarding the conclusion of Article 36 Agreements, and (2) reviewing the response procedures at Labor Standards Inspection Offices.

◆Enhancing Consultation and Support Regarding the Conclusion of Article 36 Agreements, etc.

“Specialized consultation desks” will be established at Work Style Reform Promotion Support Centers nationwide to assist with the introduction of flexible working hour systems and other measures. Additionally, teams composed of staff from the Work Style Reform Promotion Support Centers and Labor Standards Inspection Offices (Working Hours Consultation and Support Units) will conduct outreach visits to provide support regarding the conclusion of Article 36 agreements and special provisions. Furthermore, the Ministry plans to establish a system capable of addressing consultations on management issues through collaboration with “Yorozu Support Centers” and other organizations.

◆Revision of Measures at Labor Standards Inspection Offices

The authorities will revise the blanket guidance that has required limiting overtime to 45 hours per month. Instead, they will focus on verifying the implementation status of health protection measures stipulated in Article 36 Agreements at each workplace and provide necessary guidance based on the findings. Taking into account the actual conditions at individual workplaces, they will continue to provide necessary guidance in cases where there is a high risk of health problems arising from excessive work.

◆Close Attention Needed Regarding Specific Details

Based on the above, the focus of guidance provided by Labor Standards Inspection Offices has shifted from “overtime hours as a numerical figure” to “whether the health and welfare measures stipulated in the Article 36 Agreement are actually being implemented.” It may be a good idea to take this opportunity to re-examine your company’s working hour management and initiatives to address excessive working hours.

[Reference]
Ministry of Health, Labor and Welfare: “Review of Consultation, Support, and Supervision/Guidance Regarding Overtime Work, etc.”
 https://www.mhlw.go.jp/stf/newpage_75454.html